GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
Page 40 of 76
200. Defendants used Epstein’s businesses and ostensibly charitable foundations in
the Virgin Islands to make payments to the victims who were trafficked and sexually abused
while concealing these payments from detection by law enforcement authorities.
201. Defendants also prevented Epstein Enterprise entity employees from cooperating
with law enforcement by requiring them to sign confidentiality and non-disclosure agreements.
202. Defendants also actively obstructed law enforcement by denying investigators
access to Little St. James beyond its boat dock.
203. Defendants also attempted to conceal their criminal sex trafficking and abuse
conduct by paying large sums of money to participant-witnesses, including by paying for their
attorneys’ fees and case costs in litigation related to this conduct.
204. Epstein also threatened harm to victims and helped release damaging stories
about them to damage their credibility when they tried to go public with their stories of being
trafficked and sexually abused.
205. Epstein also instructed one or more Epstein Enterprise participant-witnesses to
destroy evidence relevant to ongoing court proceedings involving Defendants’ criminal sex
trafficking and abuse conduct.
206. Defendants also concealed their fraud on the Government in obtaining unearned
tax benefits by providing false testimony and submitting false and inaccurate reporting to the
Economic Development Commission to prevent detection of Defendant Southern Trust
Company’s non-compliance with requirements concerning the nature of its business and the
residency of the persons it employed.
207. The discovery of the nature, scope, and magnitude of Defendants’ unlawful
conduct and could not have been acquired earlier through the exercise of reasonable diligence.
GVI’s Second Amended Complaint
Page 40 of 76
200. Defendants used Epstein’s businesses and ostensibly charitable foundations in
the Virgin Islands to make payments to the victims who were trafficked and sexually abused
while concealing these payments from detection by law enforcement authorities.
201. Defendants also prevented Epstein Enterprise entity employees from cooperating
with law enforcement by requiring them to sign confidentiality and non-disclosure agreements.
202. Defendants also actively obstructed law enforcement by denying investigators
access to Little St. James beyond its boat dock.
203. Defendants also attempted to conceal their criminal sex trafficking and abuse
conduct by paying large sums of money to participant-witnesses, including by paying for their
attorneys’ fees and case costs in litigation related to this conduct.
204. Epstein also threatened harm to victims and helped release damaging stories
about them to damage their credibility when they tried to go public with their stories of being
trafficked and sexually abused.
205. Epstein also instructed one or more Epstein Enterprise participant-witnesses to
destroy evidence relevant to ongoing court proceedings involving Defendants’ criminal sex
trafficking and abuse conduct.
206. Defendants also concealed their fraud on the Government in obtaining unearned
tax benefits by providing false testimony and submitting false and inaccurate reporting to the
Economic Development Commission to prevent detection of Defendant Southern Trust
Company’s non-compliance with requirements concerning the nature of its business and the
residency of the persons it employed.
207. The discovery of the nature, scope, and magnitude of Defendants’ unlawful
conduct and could not have been acquired earlier through the exercise of reasonable diligence.